MU Objectives and Measures, by Stage. Bold = Core; Non-bold = Menu Red = Change to Stage 1 Criteria

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1 MU Objectives and Measures, by Stage Bold = Core; Non-bold = Menu Red = Change to Stage 1 Criteria Health General Program Meet or qualify for Requirements, Advancements and Changes exclusion to 15 core objectives and 5 of 10 menu objectives. An EP could reduce by the number of exclusions applicable the number of menu set objectives they must meet. I.e.: an EP that has an exclusion for a menu objective only must meet 4 of the 9 non-excluded menu objectives. Meet or qualify for an exclusion to 14 core objectives and 5 of 10 menu objectives. Delay Stage 2 till month EHR reporting period for providers attesting to stage 1 or 2 in 2014; future years 12 mo reporting period for those not in initial year Stage 3 to be implemented on time (2016) Core and menu set maintained; must meet or qualify for an exclusion to 17 core objectives and 3 of 6 menu items Delay Stage 2 till month EHR reporting period for providers attesting to stage 1 or 2 in 2014; future years 12 mo reporting period for those not in initial year Stage 3 to be implemented on time (2016) Core and menu set maintained; must meet or qualify for an exclusion to 16 core objectives and 3 of 6 menu items Overall, this rule is very strong, with key benefits for consumers, even with a delay of Stage 2. Stage 3 should proceed as scheduled, and future reporting periods should be12 months, rather than the 3 month reporting period for early attesters. Patients and consumers will benefit from the closing of a major loophole that allowed providers to reduce the number of criteria they had to meet in Stage 1 by qualifying for exclusions. Qualifying for an exclusion no longer reduces the number of menu objectives a provider must meet Qualifying for an exclusion no longer reduces the number of menu objectives a provider must meet 1

2 Improve quality, safety, efficiency, and reduce health disparities Use CPOE for 30% of unique patients med orders Implement one clinical decision rule relevant to specialty or high clinical priority Use CPOE for 30% of unique patients med orders Implement one clinical decision rule relevant to specialty or high clinical priority Use CPOE for medication, labs, and radiology orders Implement 5 CDS interventions related to 4 or more CQMs Use CPOE for medication, labs, and radiology orders Implement 5 CDS interventions related to 4 or more CQMs Implement drugdrug and drugallergy checks Implement drugdrug and drugallergy checks Enable and implement functionality for drug/drug and drug/allergy interaction checks for the entire EHR reporting period Enable and implement functionality for Drug/drug and drug/allergy checks have drug/drug and significant safety benefits for patients, so the drug/allergy interaction requirement that these be implemented for the checks for the entire entire reporting period will significantly benefit EHR reporting period patients. Implement drugformulary checks Generate and transmit 40% of permissible prescriptions electronically (erx) Record demographics (RELG and DOB) for 50% of unique patients Implement drugformulary checks Record demographics (RELG, DOB, and date/preliminary cause of death in the event of mortality) for 50% of unique patients More than 50% of all permissible prescriptions are generated and transmitted electronically and queried for a drug formulary More than 80% of unique patients have the following demographics recorded: - Preferred language - Sex - Race - Ethnicity - Date of birth - Date and prelim cause of death (EH only) N/A More than 80% of unique patients have the following demographics recorded: - Preferred language - Sex - Race - Ethnicity - Date of birth - Date and prelim cause of death (EH only) The lack of any appreciable advancement in the use of health IT to reduce disparities is a major shortfall. While the increase in threshold is positive, without a requirement to actually USE this data, the actual impact on disparities will be minimal. There are many missed opportunities to increase health equity in this final rule, including: - Using more granular standards for collecting demographic information - Collection of additional demographic information (disability status and SOGI) - Stratification of lists of patients generated by condition - Stratification of quality metrics : Record : Record vital signs for 50% Record and chart changes in vital signs 2 Record and chart changes in vital signs

3 vital signs for 50% of patients age 2 and over: height, weight, BP, BMI, growth charts. 2014: Record BP for 50% of patients age 3 and over, and height/weight for 50% of all patients. Record smoking status for 50% of patients 13 yo and older Incorporate 40% of lab-test results ordered into EHR as structured data Generate at least 1 report listing patients with specific condition [Note: states may elect to make this a core criteria] 20% of patients aged 65 and older or 5 years and younger were sent a reminder, per patient preference of patients age 2 and over: height, weight, BP, BMI, growth charts. 2014: Record BP for 50% of patients age 3 and over, and height/weight for 50% of all patients. Record smoking status for 50% of patients 13 yo and older Incorporate 40% of lab-test results ordered into EHR as structured data Generate at least 1 report listing patients with specific condition [Note: states may elect to make this a core criteria] N/A 50% of patients 65 years and older have an indication of an advance directive recorded for more than 80% of unique patients - Height/length - Weight - BP - BMI - Growth charts Record smoking status for more than 80% of all unique patients 13 yo and older More than 55% of all clinical lab test results incorporated as structured data Generate at least 1 report by specific condition More than 10% of all unique patients having 2 or more visits w/in 24 mos prior to reporting period sent reminder, per pt preference for more than 80% of unique patients - Height/length - Weight - BP - BMI - Growth charts Record smoking status for more than 80% of all unique patients 13 yo and older More than 55% of all clinical lab test results incorporated as structured data Generate at least 1 report by specific condition More than 50% of all unique patients 65 yo or older have advance directive status recorded as structured data Availability of electronic lab data is critical to the ability of patients managing chronic illnesses and their caregivers to be successful with self-care. Elimination of the age restrictions for reminders is a significant improvement over Stage 1. Given the wider range of individuals that will be impacted by this revision, the reduction of the threshold to 10% is still likely to result in greater numbers of individuals receiving reminders for key elements of care. Advance directives provide critical information about an individual s personal desires for his or her health care, yet this criterion was not advanced in any way. At a time when all agree that care must be better coordinated and patient-centered, and that patients must take a more active role in their care, it is a major weakness that such an established and widelyaccepted method of achieving these goals remains optional. The inclusion of family health history as a menu item is a very positive addition that both provides important longitudinal information and opportunity for inclusion of patient generated data in the EHR. 80% of patients 80% of patients Subsumed into Summary of Care Document Subsumed into Summary of Care 3

4 entry in a problem list or an indication that no problems are known 80% of all patients entry into a med list or an indication that the patient is not currently prescribed any medication 80% of all patients entry into a med allergy list or an indication that the patient does not have any med allergies entry in a problem list or an indication that no problems are known 80% of all patients entry into a med list or an indication that the patient is not currently prescribed any medication 80% of all patients entry into a med allergy list or an indication that the patient does not have any med allergies Subsumed into Summary of Care Document Subsumed into Summary of Care Document More than 10% of all imaging test results accessible through CEHRT More than 20% of all unique patients have a structured data entry for family health history (1 or more 1 st degree relatives) Document Subsumed into Summary of Care Document Subsumed into Summary of Care Document More than 10% of medication orders have all doses tracked using emar More than 10% of all imaging test results accessible through CEHRT More than 20% of all unique patients have a structured data entry for family health history (1 or more 1 st degree relatives) Though menu, the addition of a criteria focused on accessing images electronically is an important step that will help decrease costs in the form of repeat tests. Avoiding repeat tests also improves safety and convenience for patients. More than 30% of unique 4 More than 10% of hospital d/c meds queried for drug/formulary and transmitted electronically More than 30% of

5 patients have at least 1 electronic progress note created, edited and signed; must be text searchable unique patients have at least 1 electronic progress note created, edited and signed; must be text searchable Engage patients and families : 10% of patients have timely electronic access to their health information within 4 business days. 2014: 50% of all patients are provided online access to their health information, subject to EP s discretion to withhold certain info : 50% of patients receive electronic copy of their health information, upon request. 2014: Requirement eliminated. 50% of all office visits result in clinical summary being provided to patients within 3 days 10% of patients are provided patientspecific education : N/A. 2014: 50% of all patients are provided online access to their health information, within 36 hrs of d/c : 50% of patients receive electronic copy of their health information, upon request. 2014: Requirement eliminated. 10% of patients are provided patientspecific education 50% of all patients are provided online access (within 4 business days) to their health information, subject to EP s discretion to withhold certain info. 5% of all patients view, download, or transmit their health info to a 3 rd party Clinical summaries provided to patients (or patient-authorized representatives) within 1 business day for 50% of office visits. Patient-specific education resources are provided to patients for 5 Results of at least 20% of electronic lab orders received are sent to ordering provider 50% of all patients are provided online access to their health information, within 36 hrs of d/c CMS rightly holds providers accountable for 5% of all patients view, their role in patient engagement with the low download, or transmit requirement that 5% of patients actually use their health info to a 3 rd the V/D/T function once in a year. This will party incentivize providers to have a conversation with their patients about how they can access and use their health information, a key factor in whether or not patients choose to access their information when such access is available. Data show that if implemented well, about half of patients will use this feature 3 times a year or more. More than 10% of all unique patients are provided patient- Inclusion of the View/Download/Transmit criterion in both the EH and EP settings will result in greater numbers of patients having the information they need to engage in and coordinate their care, make better informed health care decisions, and live healthier lives. Secure messaging is extremely beneficial to patients and their caregivers, due to its potential impact on improving communication and subsequent improvements in care and reductions in cost. It is also a critical component of information exchange. Future stages of MU should require providers to collect patient preferences for communication (purpose and type), since some patients prefer different communication media for different purposes (e.g. mail bills but appointment reminders). CMS missed another opportunity to address

6 Improve care coordination resources, if appropriate : Conduct one test of capability to exchange key clinical information. 2013: Requirement eliminated. A summary of care record is provided to receiving provider for 50% of all referrals/transfers Med rec is performed for 50% of transitions of care resources, if appropriate : Conduct one test of capability to exchange key clinical information. 2013: Requirement eliminated A summary of care record is provided to receiving provider for 50% of all referrals/transfers Med rec is performed for 50% of transitions of care more than 10% of all office visits. 5% of all unique patients (or their authorized representative) seen during reporting period send a secure message using electronic messaging Summary of care record, including care plan and care team members, provided for 50% of transitions of care and referrals 6 specific education resources Summary of care record provided electronically for more than 10% of transitions and referrals Summary of care record provided One or more successful electronic exchanges of summary of care document with recipient who has technology designed by a different developer than sender OR one or more successful tests with the CMS designated test EHR Med rec is performed for 50% of transitions of care by receiving provider. Summary of care record, including care plan and care team members, provided for 50% of transitions of care and referrals electronically for more than 10% of transitions and referrals One or more successful electronic exchanges of summary of care document with recipient who has technology designed by a different developer than sender OR one or more successful tests with the CMS designated test EHR Med rec is performed for 50% of transitions of care by receiving provider. disparities through MU 2 by failing to require providers to use language data they are already collecting to provide educational materials in a language their patients understand. Removal of the test of exchange from Stage 1 without replacing it with any requirement for information exchange is puzzling. While there is wide agreement that the test, as written in Stage 1 was not useful, this leaves Stage 1 without any requirement for exchange of information. For Stage 2, CMS has finalized a critical advancement in care coordination and exchange of information by requiring the Summary of Care document to be exchanged electronically 10% of the time. For Stage 3, and in all future stages, the threshold for electronic exchange of SOC documents should increase significantly. Requiring one or more successful electronic exchanges of summary of care documents with a recipient who has technology designed by a different developer than the sender presents a critical opportunity to begin electronic exchange with non-mu providers (ie: SNFs and HHAs). CMS should consider opportunities to encourage this exchange through the Medicare SSP and Pioneer ACO programs. The required content of the Summary of Care Document is very strong, and the inclusion of functional status will not only provide vital information for patient-centered care, but also provides a foundation for patient reported

7 measures. While SOC document required content is very strong, CMS missed a critical opportunity to require documentation of a patient s caregiver. Documentation of caregiver name and contact information is critical for improving coordination of care, given that currently, family caregivers are the most active coordinators of care, and will continue to play a critical role in safe, effective transitions when there is a better established method of coordinating care within the health care system itself. Improve population and public health Perform one test of Perform one test of capability to submit capability to submit electronic data to electronic data to immunization immunization registries and followup submission if up submission if registries and follow- successful successful Perform one test of capability to provide electronic submission of reportable lab results to PHAs and follow-up submission if successful Perform one test of Perform one test of capability to provide capability to provide electronic syndromic electronic syndromic surveillance data to surveillance data to public health PHAs and follow-up agencies (PHAs) submission if test is and follow-up successful submission if test is successful Successful, ongoing submission to an immunization registry or immunization information system for the entire reporting period Successful ongoing submission of electronic syndromic surveillance data from CEHRT to a public health agency for the entire reporting period Successful ongoing submission of cancer case information from CEHRT to a public health agency for the entire reporting period 7 Successful, ongoing submission to an immunization registry or immunization information system for the entire reporting period Successful ongoing submission of electronic reportable lab results from CEHRT to public health agencies for the entire reporting period Successful ongoing submission of electronic syndromic surveillance data from CEHRT to a public health agency for the entire reporting period Submission of data to public health agencies and specialized registries is an important new way that the final rule advances health information exchange. The submission of case information to specialized registries is an important step toward using EHRs more effectively to measure and improve quality on the population level. Registries will likely be an important future data source for the kinds of quality measures that are most meaningful and useful to consumers, Population health is an integral part of achieving the goals of the National Quality Strategy, and population health data is absolutely essential for supporting new payment models, making submission of data to public health agencies and specialized registries a much needed foundational step toward building a health IT infrastructure that supports reform.

8 Ensure adequate privacy and security protections for personal health information Conduct or review a security risk analysis and implement security updates as necessary and correct identified security deficiencies Conduct or review a security risk analysis and implement security updates as necessary and correct identified security deficiencies Successful ongoing submission of specific case information from CEHRT to a specialized registry for the entire reporting period Conduct or review a security risk analysis, including addressing the encryption/security of stored data; implement security updates as necessary and correct security deficiencies identified in the security risk analysis Conduct or review a security risk analysis, including addressing the encryption/security of stored data; implement security updates as necessary and correct security deficiencies identified in the security risk analysis The emphasis on encryption is a positive step in a multi-faceted approach to privacy and security in health IT. Clinical Quality Measure Submission : Report clinical quality measures to CMS. 2013: Objective incorporated directly into definition of a meaningful EHR user and eliminated from functional criteria list Report 6 CQMs : Report clinical quality measures to CMS. 2013: Objective incorporated directly into definition of a meaningful EHR user and eliminated from functional criteria list Report 15 CQMs For CY 2013: report 3 core or alternate core measures and 3 menu measures For CY 2014: report 9 CQMs in at least 3 domains, OR Submit and satisfactorily report PQRS measures (must comply with changes to PQRS program) Case number threshold instituted 5 cases per quarter or 20 cases per year, consistent with Medicare hospital public reporting program For FY 2013: report all 15 CQMs finalized for Stage 1 For FY 2014: report 16 CQMs in at least 3 domains Case number threshold instituted 5 cases per quarter or 20 cases per year, consistent with Medicare hospital public reporting program The adoption of the six domains and requirement that providers submit quality data for measures in at least half of the domains is a significant improvement in the approach to CQM submission in Stage 2. The measure sets remain marginal in their usefulness, and serious gaps remain unfilled in areas of critical importance to new payment and delivery models. The EHR Incentive Program which contains no requirement for actual performance on quality metrics should be used both to improve the collection and reporting of existing quality metrics when they are meaningful and useful AND to test measures that could potentially fill measurement gaps. Alignment of MU with PQRS creates a significant need to evaluate and improve the PQRS reporting program. 8

9 Patient population designated as sampling all payer Patient population designated as sampling all payer Relevant ONC Patient ability to amend record Standards and Patient communication preferences Certification Caregiver name and contact information Rule Demographic data Components Group reporting finalized as an option; EPs must still meet functional criteria individually; Medicare SSP and Pioneer ACO programs satisfy if using CEHRT to submit CQMs; if meeting requirement through PQRS, only need to meet reporting requirement as individual in the first year of MU Included in Final ONC Rule Included in final ONC Rule Not specified Not specified beyond RELG For questions about this document or for more information about the National Partnership s Consumer Health IT Program, please contact Eva Powell at or at (202)

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